Prima Facie Case for Summons Enforcement Established

A banking institution, not the IRS, had the burden of proving at a summons enforcement hearing that its tax accrual workpapers (TAWs) were covered by the work product privilege and, therefore, the IRS summons should be quashed.

Wells Fargo & Company, DC Minn., 2011-2 USTC ¶50,526

Posted by William Alan Nelson II, Associate Editor, Wealth Strategies Journal